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  • Stephen Boulanger

Phase Two CMS Pharmacy Requirements: Part Three

Documentation of Liquid Narcotics and Fentanyl Patch Disposal

Liquid Narcotics:

Liquid controlled medications are often dispensed in multi-dose containers which indicate approximate volume. The containers may also be opaque to protect the medication from light. Because of this, absolute accuracy in tracking volume and use of liquid controlled medications may not be possible. The actual volume in these containers may be slightly over or under the manufacturer’s stated volume depending on the shape and material of the container and the formulation of the medication such as thick liquid suspensions. The opaque container, measurement markings, manufacturer fill volume variation, and method for recording usage all make detection of diversion for liquid controlled medications more difficult.

The general standard of practice for documenting usage of liquid controlled medications is to record the starting volume from the label, record each dose administered, subtract the dose administered from the previously recorded volume, and record the remaining amount.

Any observed discrepancy between the recorded amount and what appears to be remaining in the container should be reported according to facility policy. Manufacturer’s instructions may list the estimated volume variance (e.g., 30 mL plus or minus 2.5 mL).

For liquid controlled medications, signs of diversion may include:

An observable discrepancy between the written balances of remaining medication compared to the remaining amount in the bottle upon visual inspection.

Changes in the viscosity or color of the medication.

Reports of spills.

Statements from a resident that the medication is not working.

Fentanyl Patch Destruction:

Fentanyl transdermal patches present a unique situation given the multiple boxed warnings, and the substantial amount of fentanyl remaining in the patch after removal, creating a potential for abuse, misuse, diversion, or accidental exposure.

The Food and Drug Administration (FDA) and manufacturer instructions recommend that users dispose of used fentanyl patches by folding the patch in half with the sticky sides together and flushing the patch down the sink or toilet, due to the life threatening risks associated with exposure to or ingestion of the patch.

9a6d-bafcccf1959f&type=display, see section 2.4.


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